Dispute Resolution

Dispute Resolution

Have a tax audit coming up? We will support in negotiations with tax authorities or lower your risks with the help of tax rulings.

Have a tax audit coming up? Let us negotiate and write tax rulings on your behalf.

Clients benefit from Stage 5 of KPMG’s TP Lifecycle with ongoing support and assistance during tax audits or in other negotiations with tax authorities. Tax audit intensity is increasing worldwide – often with a focus on transfer pricing. A risk assessment in preparation for a tax audit can help to prepare. During an audit, we can assist with answering requests from authorities or discussing and negotiating with tax authorities. We can also help if you need assistance with mutual agreement procedures or if it comes to court cases with respect to income adjustments.

Interested in mitigating such risks? We also support you in case you would like to obtain a tax ruling or an Advance Pricing Agreement to eliminate transfer pricing risks.


Your benefits

  • Lower or no double taxation
  • Mitigated tax risk with Mutual Agreement Procedures or Advance Pricing Agreements


Our expertise

  • Support in tax audits related to transfer pricing
  • Assistance with Mutual Agreement Procedures and Advance Pricing Agreements
  • Global management of tax audits
  • Preparation of tax rulings regarding transfer pricing


Transfer pricing has become much more complex in view of the ongoing digitalization, new business models and increasing transparency. Multinational groups need a partner that provides guidance through this complexity. We help to identify risks and opportunities, plan a sustainable and pragmatic transfer pricing system, support compliance, and manage risks arising in tax audits, thus driving value and maintaining reputation.

We understand the needs of our clients and call this continuous and sustainable improvement process “KPMG's TP Lifecycle”.

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